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between a weakened legal sector and the illegal sector operating without these restrictions is becoming bigger and bigger. So that’s one thing that worries us and this is likely to actually reduce the tax take from online gambling overall. SP: Are there other areas where you feel policy makers are working against the common objectives of organizing a successful licensed market? MG: Over the past 2-4 years we have come up with quite a lot of measures which have had a big impact. But at some point this becomes more complex. In the Netherlands, we just passed legislation limiting the maximum stake to €700 per month per operator. As a result, we now see that average losses per person have reduced from more than €160 per month to around €115, so a third less. From a policy view, that’s good news: people are losing less. But the combination of these policy measures, the tax hike and the stake limits have made it difficult for the sector. I must emphasize that over 90 percent of people still gamble exclusively in the licensed market, but what we are seeing this year for the first time is that over half the total money staked went to the illegal sector. This is a big shift to the illegal market. The data is not perfect ,but it seems clear that the bigger gamblers have left the legal market and gone to the black market. SP: So, it seems clear that this combination of legislative measures has harmed the regulated market in the Netherlands. How much responsibility do the licensed operators bare for the situation and what could they do to help bring about a more positive atmosphere towards gambling? MG: We have already talked about the tidal wave of advertising and how that turned people off gambling, but the lessons are still not being learned in, for example, duty of care which is a core objective of Dutch regulation. To give an example, last week, we published a fine of €4 million against a licensee for failures in player protection and duty of care. The party concerned responded publicly by saying we disagree with the KSA, we think everything was really open back then, so we don’t think we broke any rules. Now, that may be an argument to make in court but to say it in public looks like they only care about the money and not the player.
tightened, but to try to explain that to a Dutch audience looks like the operator has missed the point. The original legislation was deliberately open and relied on operators to set standards of behavior. Successive enforcement actions have added layers of interpretation of rules and ultimately rules were tightened at their request to make the situation clear. That doesn’t mean it was a free-for-all up to that point. That was never the intention. I understand, as an individual operator, they have to survive in a competitive market, yes, but as a group, the result has been that tolerance for the gaming industry has diminished a lot and they have to share responsibility for that. SP: Are there positive things that the industry is doing and could do more to help the situation? MG: I think that at a certain level, the industry is helping. For the first time, we have managed to create a kind of alliance, an independent body, with representatives from government, the industry, affiliates, payment service providers and other partners to fight illegal operators. I’m not sure this is the complete answer but the politicians I speak with are enthusiastic about it. The industry certainly has the same objective, but we have a lot of ground to make up. SP: That brings us on to the second dimension, that of the black market. You have made some interesting and quite radical suggestions recently about how the industry as a whole, how regulators internationally can work together, can take various actions, perhaps even an Interpol for gambling, to tackle the black market. Perhaps you could expand on that area for us. MG: Individual regulators have limited capacity and this is completely normal. Indeed, it would be strange if we had unlimited resources. But this doesn’t have to be the end of the story. We know, for instance, that of the 20 biggest illegal operators targeting the UK, six of them are in also in our top 10. That’s the same for many European markets: we are up against common adversaries. So, if our British, Swedish, Danish or Italian colleagues have already investigated a company and collected evidence about how it operates, it could be very helpful if we are also able to use this material in our courts. I am a board member of GREF, the Gambling Regulators European Forum and a member of IAGR the International
It may be true that the fine relates to a period before rules were
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IMGL MAGAZINE | DECEMBER 2025
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